records management oversight inspection report …management self-assessment (rmsa).1 past scores on...

RECORDS MANAGEMENT OVERSIGHT

INSPECTION REPORT

2014

National Transportation Safety Board

Records Management Program

NATIONAL ARCHIVES and RECORDS ADMINISTRATION Issued December 19, 2014

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EXECUTIVE SUMMARY

In 2014, the National Archives and Records Administration (NARA) inspected the National

Transportation Safety Board (NTSB). NARA conducted this effort under the authority granted it

by 44 United States Code (U.S.C.) 2904(c)(7) and 2906 to inspect records management programs

and practices of Federal agencies. This inspection was prompted by NTSB scores on the Records

Management Self-Assessment (RMSA).1 Past scores on NARA’s RMSA consistently put NTSB

in the high risk category (score of 35 on RMSA 2012, 50 on RMSA 2011, 39 on RMSA 2010,

and 56 on RMSA 2009). This inspection was also warranted because of the following:

• NTSB has not submitted schedules in more than 15 years. • NTSB indicates on the RMSA that they do not have any permanent records. • It is unclear what NTSB has been doing with their records in terms of disposition. • There has been internal consolidation of field offices. • An electronic document management system (EDMS) is currently being implemented

for all NTSB records.

The overall objective of this inspection was to determine if the records management programs at

the NTSB are in compliance with regulations under 36 Code of Federal Regulations (CFR)

Chapter XII, Subchapter B.

The NTSB is an independent Federal agency charged by Congress with investigating every civil

aviation accident in the United States and significant accidents in other modes of transportation,

railroad, highway, marine and pipeline. The NTSB determines the probable cause of the

accidents and issues safety recommendations aimed at preventing future accidents. In addition,

the NTSB carries out special studies concerning transportation safety and coordinates the

resources of the Federal Government and other organizations to provide assistance to victims and

their family members impacted by major transportation disasters.

The NTSB has five Board Members, each nominated by the President and confirmed by the

Senate to serve five-year terms. A Member is designated by the President as Chairman and

another as Vice Chairman for two-year terms. The Chairmanship requires separate Senate

confirmation. When there is no designated Chairman, the Vice Chairman serves as Acting

Chairman.

The NTSB began its shift to electronic storage of docket items with an in-house developed

application in the early 1990s. In 2002, the NTSB implemented its docket management system

(DMS), a contractor developed system, to manage dockets electronically. Over the past few

years the NTSB has continued its shift from paper-based business processes to electronic-based

business processes. In addition to upgrading the original DMS, the NTSB has introduced the

1 Records Management Self-Assessment Reports 2009-2012, National Archives and Records Administration,

http://www.archives.gov/records-mgmt/resources/self-assessment.html.

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Executive Summary

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Office of the Chief Records Officer 2014

Correspondence Control, Notation and Safety Recommendation (CNS) System and an enhanced

Aviation Database Management System (ADMS) to collect and manage records electronically.

Collectively, these systems support a shift from a paper-based environment to an electronic-

based environment built around an electronic document management system (EDMS). NTSB has

made major progress in migrating all records maintained at the agency to the EDMS. The records

management program has the full support of the Chief Information Officer (CIO).

During the course of the inspection, NARA visited or had briefings from multiple NTSB

program offices at NTSB Washington, D.C. headquarters and the NTSB Training Center in

Ashburn, Virginia. The NTSB program staff and the enthusiastic RM staff demonstrated

dedication to ensuring records are managed throughout their lifecycle. While we found a very

engaged records management program, we found areas of concern that need attention.

FINDINGS AND RECOMMENDATIONS

This report contains 12 findings and makes 14 recommendations. The main concerns covered in

this report include:

1. Records inventory, scheduling and disposition process require further development and implementation.

2. Records management procedures and training require further development and implementation.

3. Evaluations or formal assessments should be conducted to ensure compliance with policies, procedures and standards.

4. Electronic records policies and procedures should be developed and implemented, which includes incorporating records management in all electronic system designs, migration

and managing shared drives.

A complete list of findings and recommendations is included as Appendix C.

To ensure completion of the recommendations, as part of the inspection process, NTSB will be

required to develop a Plan of Corrective Action (PoCA) that specifies how the agency will

address each report recommendation, including a timeline for completion of the corrective

action(s) for each recommendation. NARA will analyze the proposed remedial actions and work

with NTSB to ensure the adequacy of its PoCA. Upon approval of the PoCA, NARA looks

forward to continuing a cooperative relationship with NTSB and assisting with the

implementation of the recommendations.

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iiOffice of the Chief Records Officer 2014

TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................................................................. i

INTRODUCTION ............................................................................................................................1

BACKGROUND .............................................................................................................................1

INSPECTION OBJECTIVE ................................................................................................................3

SCOPE AND PURPOSE ....................................................................................................................5

SECTION 1: RECORDS SCHEDULING AND DISPOSITION REQUIREMENTS .........................................6

SECTION 2: RECORDKEEPING REQUIREMENTS ..............................................................................8

SECTION 3: PROGRAM REQUIREMENTS .........................................................................................9

SECTION 4: ELECTRONIC RECORDS REQUIREMENTS ................................................................... 10

APPENDICES

APPENDIX A: RELEVANT PRE-INSPECTION DOCUMENTS

APPENDIX B: AUTHORITIES AND FOLLOW-UP ACTIONS

APPENDIX C: COMPLETE LIST OF FINDINGS AND RECOMMENDATIONS

APPENDIX D: OFFICES VISITED DURING INSPECTION

APPENDIX E: SELECTED COMPLIANCE QUESTIONS

APPENDIX F: ACRONYMS AND ABBREVIATIONS

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NATIONAL TRANSPORTATION SAFETY BOARD

RECORDS MANAGEMENT PROGRAM

INSPECTION REPORT

INTRODUCTION

BACKGROUND

The National Transportation Safety Board (NTSB) is an independent Federal agency responsible

for investigating and determining the probable cause of every civil aviation accident in the

United States and significant accidents in other modes of transportation. The NTSB develops

recommendations in order to prevent future accidents or reduce their negative effects.

The NTSB promotes transportation safety, assists victims of transportation accidents and their

families, conducts safety studies, and prepares accident reports. NTSB investigations are used to

determine factors common to a series of events and to identify safety improvements or evaluate

the worth of transportation related devices or policies.

Since its inception in 1967, the NTSB has investigated more than 139,000 aviation accidents and

thousands of surface transportation accidents. It has issued more than 13,800 safety

recommendations to more than 2,300 recipients in all transportation modes as a result of its

investigations.

The NTSB has several lines of business. These lines of business are:

Office of Aviation Safety (AS)

Office of Highway Safety (HS)

Office of Marine Safety (MS)

Office of Railroad, Pipeline, and Hazardous Materials Investigations (RPH)

Office of Research and Engineering (RE)

Office of Communications (OC)

Office of Administration (AD)

Office of Administrative Law Judges (ALJ)

Office of the Chief Information Officer (CIO)

Office of Equal Employment Opportunity, Diversity, and Inclusion (EEODI)

Office of the Chief Financial Officer (CFO)

Office of General Counsel (GC)

Office of the Managing Director (MD)

National Transportation Safety Board (NTSB)


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Structure of the NTSB

The NTSB has five Board Members, each nominated by the President and confirmed by the

Senate to serve 5-year terms. One Member is designated by the President as Chairman and

another as Vice Chairman for 2-year terms. The chairmanship requires separate Senate

confirmation. When there is no designated Chairman, the Vice Chairman serves as Acting

Chairman.

The Board may hold an investigative hearing as part of a major transportation accident

investigation. The purpose of the hearing is two-fold; first, to gather sworn testimony from

subpoenaed witnesses on issues identified by the Board during the course of the investigation,

and, second, to allow the public to observe the progress of the investigation. Hearings are usually

held within six months of an accident but may be delayed for complex investigations.

The Office of the Managing Director assists the Chairman in the discharge of the Chairman’s

functions. The office provides overall leadership for the management of the agency, including

production, strategy, and support functions. The office ensures that NTSB resources are allocated

appropriately.

The NTSB’s headquarters office is located in Washington, DC. The NTSB also has investigators

located in Ashburn, Virginia; Denver, Colorado; Anchorage, Alaska; and Seattle, Washington.

The Office of Aviation Safety has staff throughout the United States.

The NTSB "Go Team"

At the core of NTSB investigations is the "Go Team," the purpose of which is to begin the

investigation of a major accident as quickly as possible, assembling the broad spectrum of

technical expertise that is needed to solve complex transportation safety problems. The team can

number from three or four to more than a dozen. The Go Team's immediate boss is the

Investigator-in-Charge (IIC). Each investigator is a specialist responsible for a clearly defined

portion of the accident investigation.

Under direction of the IIC, each of these NTSB investigators heads what is called an

"investigative group" in one area of expertise. Each is, in effect, a subcommittee of the overall

investigating team. The groups are staffed by representatives of the "parties" to the investigation,

the Federal Aviation Administration, the airline, the pilots' and flight attendants' unions, airframe

and engine manufacturers, and the like. Eventually, each investigative group chairman prepares a

factual report, and each of the parties in the group is asked to verify the accuracy of the report.

The factual reports are placed in the public docket.



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Investigative Hearing

The Board may hold an investigative hearing as part of a major transportation accident

investigation. The purpose of the hearing is two-fold; first, to gather sworn testimony from

subpoenaed witnesses on issues identified by the Board during the course of the investigation,

and, second, to allow the public to observe the progress of the investigation. Hearings are usually

held within six months of an accident but may be delayed for complex investigations.

The Remainder of the Investigation and Final Report

More months of tests and analysis eventually lead to the preparation of a draft final report by

Safety Board staff. Parties do not participate in the analysis and report writing phase of NTSB

investigations; however, they are invited to submit their proposed findings of cause and proposed

safety recommendations, which are made part of the public docket. The Board then deliberates

over the final report in a public Board meeting.

Once a major report is adopted at a Board Meeting, an abstract of that report - containing the

Board's conclusions, probable cause and safety recommendations - is placed on the Board's web

site under "Publications". The full report typically appears on the web site several weeks later.2

INSPECTION OBJECTIVE

In 2014, NARA inspected elements of the records management program at the NTSB. NARA

conducted this effort under the authority granted it by 44 U.S.C. 2904(c)(7) and 2906 to inspect

records management programs and practices of Federal agencies. The overall objective of this

inspection was to determine if the records management programs at the NTSB are in compliance

with regulations under 36 CFR Chapter XII, Subchapter B. At a more granular level, the

inspection sought to determine if the records management programs at NTSB are in compliance

with:

36 CFR 1222.34 Agencies must implement a records maintenance program so that complete records are filed or otherwise identified and preserved, records can be readily

found when needed, and permanent and temporary records are physically segregated

from each other or, for electronic records, segregable.

36 CFR 1224.10(a) Agencies must ensure that all records are scheduled in accordance with part 1225 of this subchapter, schedules are implemented in accordance with part

1226 of this subchapter, and permanent records are transferred to the National Archives

of the United States.

2 The description of NTSB’s function, organization, mission, and business processes are taken from the NTSB’s

Performance Accountability Report dated 2013.



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36 CFR 1224.10(d) Agencies must incorporate records retention and disposition functionality during the design, development, and implementation of new or revised

recordkeeping systems (whether paper or electronic). See § 1236.6 of this subchapter.

36 CFR 1226.10 The application of approved schedules is mandatory except as provided in § 1226.16 and 1226.18. Federal records must be retained as specified in the schedule to

conduct Government business, protect rights, avoid waste, and preserve permanent

records for transfer to the National Archives of the United States.

36 CFR 1226.22 All records scheduled as permanent must be transferred to the National Archives of the United States after the period specified on the SF 115 (Standard Form

115: Request for Records Disposition Authority) in accordance with procedures specified

under § 1235.12 of this subchapter.

36 CFR 1232.14(a) Agencies must ensure that the requirements of 36 CFR part 1234 are met. Special attention must be paid to ensuring appropriate storage conditions for records

on non-paper based media (e.g., film, audio tape, magnetic tape), especially those that are

scheduled for long-term or permanent retention, as those records typically require more

stringent environmental controls (see 36 CFR parts 1236 and 1237).

36 CFR 1235.12 Permanent records must be transferred to the National Archives of the United States when: (a) The records are eligible for transfer based on the transfer date

specified in a NARA-approved records schedule, or (b) The records have been in

existence for more than 30 years (see also § 1235.14).

36 CFR 1235.14(a) Agencies may retain records longer than specified on a records disposition schedule only with written approval from NARA.

36 CFR 1236.6 Agencies must: (a) Incorporate management of electronic records into the records management activities required by parts 1220-1235 of this subchapter; (b)

Integrate records management and preservation considerations into the design,

development, enhancement, and implementation of electronic information systems in

accordance with subpart B of this part; and (c) Appropriately manage electronic records

in accordance with subpart C of this part.



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SCOPE AND PURPOSE

The purpose of this inspection was to determine if the NTSB records management program had

sufficient policies and procedures to appropriately manage active and inactive records, make the

transition from paper to electronic records management, and ensure the transfer of permanently

valuable records to the National Archives.

METHODOLOGY

To meet the objective of assessing whether the NTSB is managing their records appropriately the

inspection team examined NTSB’s records management activities in light of applicable records

management sections of the 36 Code of Federal Regulations (CFR) Chapter XII, Subchapter B.

To ensure that our inquiries into NTSB’s records management practices were systematic and

grounded in regulation, the NARA inspection team relied on an internally produced set of

records management questions that correlate directly to the CFR (These questions are included

as Appendix E of this report). Each of the NTSB business lines was given a chance to respond to

questions, provide documentation, and to demonstrate various a8.8spects of their records

management programs.

As part of the pre-inspection process, the NARA inspection team conducted its own background

research. Additionally, NTSB provided documentation for various elements of its records

management practices and procedures many of which were useful to the inspection team as

background information. Others were more central in documenting and supporting the findings

and recommendations of this inspection. A summary list of pre-inspection documentation

requested for this inspection can be found in Appendix A.

During the course of the inspection, NARA visited or had briefings from multiple NTSB

program offices at NTSB headquarters and at the Region office in Ashburn, Virginia.

STRUCTURE OF THE REPORT

NTSB staff was asked to discuss each of the following areas and to provide any supporting

documentation as needed. Discussions during site visits included mission or program staff as

necessary to help records management staff describe implementation of records management

policies, standards, procedures, retention schedules and other tactics, including the realm of

electronic recordkeeping.

The findings and recommendations of this report are broken down into four topical areas:

Section 1, Records Scheduling and Disposition Requirements; Section 2, Recordkeeping

Requirements; Section 3, Program Requirements; and Section 4, Electronic Records

Requirements.



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In accordance with 36 CFR 1239 this report contains:

(1) An executive summary; (2) Background and purpose of inspection; (3) Inspection methodology, including offices visited; (4) Findings; (5) Corrective actions needed and other recommendations; and (6) Any necessary appendices, such as summaries of each site visit or the inspection

instrument.

FINDINGS AND RECOMMENDATIONS

During the course of the inspection the NTSB staff demonstrated the desire to ensure records are

maintained and information made available. The main method being deployed to achieve this

goal is shifting from a paper-based environment to an electronic-based environment using an

electronic document management system (EDMS). NTSB has made major progress in migrating

records to the EDMS. Some of the major migrations have included docket management

(OpenText), accident investigation records (Sharepoint), correspondence control, notations, and

safety recommendation records (Sharepoint). NTSB plans to implement the OpenText

application governance and archiving (AGA) module for both EDMS environments. The

majority of NTSB work is done outside of the traditional office environment. Maintaining these

records in an EDMS enables NTSB staff to create and access information needed to perform

their function regardless of location. The records management program appears to have the full

support of the Chief Information Officer (CIO).

However, there are several areas of concern that are basic to the foundation of a solid and

dynamic records management program.

SECTION 1: RECORDS SCHEDULING AND DISPOSITION REQUIREMENTS

A compliant, effective, and efficient Federal records management program requires that each

agency ensure that all records are covered by a NARA-approved records retention and

disposition schedule so that records are retained as long as needed for business purposes; to meet

legal and fiscal requirements; and to preserve records with permanent and enduring value.

Agencies must also ensure that these records schedules are implemented and that records are

disposed of in accordance with these NARA-approved schedules.

1.1 Finding: NTSB does not currently have a consolidated records inventory that includes

information about where records are physically located, that identifies vital records, and that

includes other information about records essential to a comprehensive inventory.

1.1. Recommendation: NTSB should conduct a thorough office by office and/or line of

business comprehensive inventory of all records regardless of media. The inventory

should include the identification of vital records. (36 CFR 1220-1226)



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1.2 Finding: NTSB is not scheduling its records. As such, the agency is at risk of destroying

records prematurely, maintaining records longer than necessary, and failing to transfer

permanent records to the National Archives when appropriate.

The NTSB responded to past RMSA’s indicating that it does not create or maintain permanent

records; and therefore does not transfer records to NARA. The only way for an agency to

properly make this determination is through submitting records retention schedules to NARA.

The NTSB has not submitted a schedule to NARA in 15 years. By not following this basic

records management function, the NTSB decreases it ability to ensure records management

processes account for business information needs; aid in accountability, as well as, risks failure

to transfer permanent records to NARA.

To facilitate the use of records retention schedules, 36 CFR 1225 and 1226 prescribe the

requirements for implementing records disposition. The requirements include disposing of

inactive temporary records when retention periods have expired and transferring permanent

records to the National Archives when retention periods have been met. Effective disposition of

records requires having usable records retention schedules. Prior to developing and

implementing records retention schedules, an active and vibrant records inventory must be

maintained that results in the development, implementation and maintenance of compliant

records schedules.

1.2 Recommendation: Develop, coordinate and implement a records retention scheduling

program to improve records disposition for NTSB permanent and temporary records.

1.3Finding: NTSB does not adequately respond to notifications of records eligible for disposal

from the WNRC.

NTSB stores its inactive records at the Washington National Records Center (WNRC). As a

matter of routine, the Federal Records Centers (FRCs) send disposal notices out to agencies for

all records eligible for destruction. It is the customer agency’s responsibility to verify that

disposal of these records can take place by signing and returning disposal notices to the FRC.

The FRCs do not dispose of any records without this final approval. The NTSB records

management staff were unaware of the procedures, and while they have been receiving the

disposal notices, they have not been appropriately responsive to them.

1.3.1 Recommendation: Establish policies and procedures for handling disposal notices

from the FRC in a timely fashion.

1.3.2 Recommendation: Coordinate with the FRC to handle existing disposal notices in

order to dispose of all eligible records.



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SECTION 2: RECORDKEEPING REQUIREMENTS

A compliant, effective, and efficient Federal records management program is based upon the

establishment of recordkeeping requirements for records in all media. Recordkeeping

requirements include clear guidance and the appropriate determination of what constitutes a

record and distinguishes records from non-record material and personal papers. Recordkeeping

requirements should specify the creation and maintenance of specific records to document

agency operation and activities; ensure that all records are covered by a records retention and

disposition schedule; protect records from removal or alienation; define records management

responsibilities; and provide training.

2.1 Finding: NTSB has weak to non-existent procedures in place for ensuring a compliant

records management program.

NTSB’s records management program is implemented through operations bulletins that contain a

mixture of policy and guidance. Policy, however, needs to be supported by procedures that

instruct staff on how to comply with existing policies. No written procedures currently exist to

tell staff how to implement NTSB records management policies and guidance; however, staff

appears to be aware of whom to ask if they have a records-related question.

2.1.1 Recommendation: Develop, update and implement applicable 36 CFR 1222

compliant standards, policies and procedures.

2.1.2 Recommendation: Disposition records according to 36 CFR 1222 and NARA-

approved records schedules.

2.2 Finding: NTSB does not offer records management training to new employees.

NTSB has drafted a records management briefing for new employees, but the briefing is not yet

being given. However, employees are alerted via an operations bulletin as to their responsibilities

vis–à–vis records.

2.2 Recommendation: Complete and implement the new employee records management

training. (36 CFR 1222.24)

2.3 Finding: NTSB does not have a records management exit briefing for departing staff and

senior officials.

2.3 Recommendation: Complete and implement an RM exit briefing and process for

departing staff and senior officials. (36 CFR 1222.24)



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2.4 Finding: The NTSB records management training program is under development.

According to 36 CFR 1220.34, agencies are required to provide “guidance and training to all

agency personnel on their records management responsibilities.” The OMB/NARA Managing

Government Records Directive (M-12-18) also requires that agencies establish records

management training.

At the time of the inspection site visit, an online records training module for all employees was

under development. Upon completion, all staff will be required to take this training annually.

NARA supports the development of this training as well as the requirement that employees take

the training annually.

2.4 Recommendation: NTSB should update NARA on the progress of the training

program development and provide a demonstration when completed.

SECTION 3: PROGRAM REQUIREMENTS

A compliant, effective, and efficient Federal records management program requires senior

management support at the highest levels; a clear definition of program objectives,

responsibilities, and authorities; allocation of sufficient resources to administer the program;

assignment of the program to an appropriate office within the agency’s organizational structure;

continuous training for records management staff; and regular internal evaluations to monitor

compliance and program effectiveness.

3.1 Finding: NTSB’s Records Management Program does not conduct periodic evaluations of

records management practices. (36 CFR 1220.34)

Conducting periodic evaluations provides documentation on how well various offices comply

with records schedules and other aspects of records management. They provide opportunities to

identify areas that need improvement as well as areas that are working well and could serve as

models to other parts of the program. In conducting evaluations, the NTSB records management

program can increase its visibility, building opportunities for briefings, training, and additional

dissemination of records management information.

3.1 Recommendation: NTSB should conduct evaluations to measure the effectiveness of

records management practices within the agency and to ensure compliance with NARA

regulations. (36 CFR 1220.34)



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SECTION 4: ELECTRONIC RECORDS REQUIREMENTS

A compliant, effective, and efficient Federal records management program requires

incorporation of the management of electronic records into records management activities;

integration of records management functionalities and preservation considerations into the

design, development, enhancement, and implementation of electronic information systems; and

appropriate management of electronic records.

The NTSB is developing and implementing an EDMS that will facilitate managing the agency’s

records and information. The EDMS system provides the NTSB means to electronically manage

the vast majority of agency records while providing public access to most of the agency’s

records and information. Once the NTSB fully implements the EDMS RM module, they will

have a fully integrated records and information management system ensuring the effective and

efficient use of the agency’s information resources.

However, in order to be successful there are several things that need to be considered.

4.1 Finding: Records management considerations are not incorporated into NTSB’s

Electronic Document Management System (EDMS), also known as the Docket Management

System (DMS).

The records management program staff at NTSB is working closely with IT staff to establish an

EDMS with records management requirements. However, at the time of inspection, it was not

yet in place.

4.1 Recommendation: NTSB should implement plans to incorporate a records

management module into its EDMS thereby providing records management functionality

including the scheduling and disposition of records. NARA should be notified when this

effort is completed. (36 CFR 1236)

4.2 Finding: NTSB lacks agency policy on the integration of records management

considerations into the design and development of electronic information systems.

The Code of Federal Regulations requires that “recordkeeping functionality be built into

electronic information system[s]” (36 CFR 1236.20). This functionality is also required by the

Information Management Policy, part (k) that is contained in OMB Circular A-130. NTSB has

weak to non-existent procedures in place for ensuring that the appropriate records management

requirements are included in the review and approval process for new electronic information

systems or enhancements to existing systems. NTSB needs to develop policy and procedure to

ensure recordkeeping functionality is incorporated in all electronic systems.

4.2 Recommendation: Develop and implement policy to incorporate records management

functionality requirements into existing and future electronic information systems. (36

CFR 1236.20)



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4.3 Finding: There are no policies and procedures related to storing records and information

on shared drives or for the proper storage of electronic records generally.

NTSB’s electronic records consist of unstructured data maintained on shared drives that are

generally managed and “owned” by the various program/line of business offices. RM staff does

not provide guidance or training on the use of shared drives. In addition, no policy or procedures

exist to identify records or indicate location of the official record copy. NTSB needs to properly

maintain electronic files in accordance with NARA standards.

4.3 Recommendation: Assist offices in creating and documenting standardized electronic

filing practices for electronic records stored on shared drives, including file structures,

naming conventions, taxonomies, and acceptable formats. (36 CFR 1236)

4.4 Finding: Long-term temporary and potentially permanent electronic records are

maintained on a wide variety of media and have never been migrated to new media as required

for preservation and accessibility.

Most NTSB agency program records are maintained electronically using a wide variety of media.

Occasionally, as the need arises, some records are migrated to new formats and media. However,

this activity is not done in a routine or planned manner, which could contribute to loss of

information or the inability to retrieve records due to obsolescence of hardware and/or software.

4.4 Recommendation: Develop and implement electronic records migration policies and

procedures to transfer data from the obsolete media to new media. (36 CFR 1236.14)

CONCLUSIONS AND SUMMARY

Although the agency is proactive in implementing technology to manage its records and

information holdings, a lot of foundational work must be developed and implemented to ensure

compliance with Federal regulations. Some of this work will be critical to the successful rollout

of the EDMS and the RM module. First, a records inventory, scheduling and disposition process

requires further development and implementation. After completing those activities NTSB

should develop and implement records management procedures and training. Regular

evaluations or formal assessments should be conducted to ensure compliance with policies,

procedures and standards. Finally, electronic records policies and procedures should be

developed and implemented, which includes incorporating records management in all electronic

system designs, migration and managing shared drives.

APPENDIX A

RELEVANT PRE-INSPECTION DOCUMENTS

The inspection team requested that NTSB provide NARA with copies of:

All current NTSB records management directives, orders, bulletins, and similar authoritative issuances;

Revisions to disposition authorities or manuals not yet submitted or approved by NARA;

The current master file plan;

Any current guidance/memoranda formally assigning responsibility for development and implementation of guidance for the management of electronic media;

Any current Electronic Document Management Systems and/or Records Management Applications technical requirements documents; and

Any RM requirements incorporated into IT design and development.

APPENDIX B

AUTHORITIES AND FOLLOW-UP ACTIONS

AUTHORITIES

44 U.S.C. Chapter 29

36 CFR Chapter XII, Subchapter B

36 CFR 1239, Program Assistance and Inspections

FOLLOW-UP ACTIONS

ACTION PLAN

NTSB will submit to NARA a Plan of Corrective Action (PoCA) that specifies how the

agency will address each inspection report recommendation, including a timeline for

completion and proposed progress reporting dates.

The plan must be submitted within 60 days after the date of transmittal of the final report

to the head of the agency.

PROGRESS REPORTS

NTSB will submit to NARA progress reports on the implementation of the action plan

until all actions are completed.

NARA REVIEW

NARA will analyze the adequacy of NTSB’s action plan, provide comments to NTSB on

the plan within 60 calendar days of receipt, assist NTSB in implementing

recommendations, and inform NTSB when progress reports are no longer needed.

National Archives and Records Administration Page C-1

Office of Records Management Oversight 2014

APPENDIX C

COMPLETE LIST OF FINDINGS AND RECOMMENDATIONS

Section 1: Records Scheduling and Disposition Requirements

1.1 Finding: NTSB does not currently have a consolidated records inventory that includes

information about where records are physically located, that identifies vital records, and that

includes other information about records essential to a comprehensive inventory.

1.1 Recommendation: NTSB should conduct a thorough office by office and/or line of

business comprehensive inventory of all records regardless of media. The inventory

should include the identification of vital records. (36 CFR 1220-1226)

1.2 Finding: NTSB is not scheduling its records. As such, the agency is at risk of destroying

records prematurely, maintaining records longer than necessary, and failing to transfer

permanent records to the National Archives when appropriate.

1.2 Recommendation: Develop, coordinate and implement a records retention scheduling

program to improve records disposition for NTSB permanent and temporary records.

1.3 Finding: NTSB does not adequately respond to notifications of records eligible for disposal

from the WNRC.

1.3.1 Recommendation: Establish policies and procedures for handling disposal notices

from the FRC in a timely fashion.

1.3.2 Recommendation: Coordinate with the FRC to handle existing disposal notices in

order to dispose of all eligible records.

Section 2: Recordkeeping Requirements

2.1 Finding: NTSB has weak to non-existent procedures in place for ensuring a compliant

records management program.

2.1.1 Recommendation: Develop, update and implement applicable 36 CFR 1222

compliant standards, policies and procedures.

2.1.2 Recommendation: Disposition records according to 36 CFR 1222 and NARA-

approved records schedules.



Appendix C



2.2 Finding: NTSB does not offer records management training to new employees.

2.2 Recommendation: Complete and implement the new employee records management

training. (36 CFR 1222.24)

2.3 Finding: NTSB does not have a records management exit briefing for departing staff and

senior officials.

2.3 Recommendation: Complete and implement an RM exit briefing and process for

departing staff and senior officials. (36 CFR 1222.24)

2.4 Finding: The NTSB records management training program is under development.

2.4 Recommendation: NTSB should update NARA on the progress of the training

program development and provide a demonstration when completed.

Section 3: Program Requirements

3.1 Finding: NTSB’s Records Management Program does not conduct periodic evaluations of

records management practices. (36 CFR 1220.34)

3.1 Recommendation: NTSB should conduct evaluations to measure the effectiveness of

records management practices within the agency and to ensure compliance with NARA

regulations. (36 CFR 1220.34)

Section 4: Electronic Records Requirements

4.1 Finding: Records management considerations are not incorporated into NTSB’s Electronic

Document Management System (EDMS), also known as the Docket Management System (DMS).

4.1 Recommendation: NTSB should implement plans to incorporate a records

management module into its EDMS thereby providing records management functionality

including the scheduling and disposition of records. NARA should be notified when this

effort is completed. (36 CFR 1236)

4.2 Finding: NTSB lacks agency policy on the integration of records management considerations

into the design and development of electronic information systems.

4.2 Recommendation: Develop and implement policy to incorporate records management

functionality requirements into existing and future electronic information systems. (36

CFR 1236.20)



Appendix C



4.3 Finding: There are no policies and procedures related to storing records and information on

shared drives or for the proper storage of electronic records generally.

4.3 Recommendation: Assist offices in creating and documenting standardized electronic

filing practices for electronic records stored on shared drives, including file structures,

naming conventions, taxonomies, and acceptable formats. (36 CFR 1236)

4.4 Finding: Long-term temporary and potentially permanent electronic records are maintained

on a wide variety of media and have never been migrated to new media as required for

preservation and accessibility.

4.4 Recommendation: Develop and implement electronic records migration policies and

procedures to transfer data from the obsolete media to new media. (36 CFR 1236.14)

APPENDIX D

OFFICES VISITED DURING INSPECTION

Site visits: o June 17-18, 2014: NTSB Headquarters – Washington, DC o June 19, 2014: Field Office – Ashburn, VA

National Archives and Records Administration Page E-1


APPENDIX E

SELECTED COMPLIANCE QUESTIONS

The following is a list of questions based on the CFR and other NARA guidance used to gather

information during the course of this inspection. The questions are divided into specific records

management topics.

Senior Agency Official

Does NTSB have a Senior Agency Official (SAO) designated in response to M-12-18 OMB/NARA Managing Government Records Directive?

o If yes, does the Records Officer have any direct communication with the SAO or is this done through other levels of management?

Records Management Program Structure

Does the records management program continue to report to the Office of the Chief Information Officer?

Is the records management program adequately represented within senior management? (Determined by the inspection team during the course of the inspection)

Records Officer

Does the RO have formally assigned responsibility for the development and implementation of agency-wide programs to identify, develop, issue, and monitor

recordkeeping requirements for the agency?

If no, who at NTSB is formally assigned this responsibility?

Describe the responsibilities and duties of the NTSB Records Officer, including but not limited to the following:

Does the NTSB Records Officer (RO):

o Identify unscheduled records and submit to NARA requests for disposition authority through ERA?

o Approve and review SF 135s for records stored off-site by NARA’s Federal Records Center Program?

o Mandate records management training for all staff, covering especially employees’ responsibility to identify and manage the Federal records in their

control?

o Conduct audits, reviews, and/or evaluations? o Work with IT to ensure records management functionality is incorporated into

systems? If yes, is the RO recognized as a stakeholder in the design and

development process for IT systems?



Appendix E



Records Management Program Staffing

In addition to the RO, does NTSB have other staff with full-time records management responsibilities? If yes,

o How many? o What responsibilities do they have? o Is records management included in their position description?

Does NTSB have a network throughout the agency to assist the RM program? (NARA refers to these as Records Liaison Officers (RLO), but agencies may have a different

title.) If yes,

o Where do the Records Officer and Records Liaison Officers fit into the organizational structure?

o Are there RLOs in each office or program? If yes, is there an established description of what RM expects the RLO to do? If yes, please provide a copy.

o Are the RLO duties included in the official duties or is it an ad hoc ‘other duties as assigned’ fashion?

o Please describe the relationship between the RO and the RLOs including forms of communication, how often, and if this is an established working group that

interacts with each other.

o What support from office heads or program supervisors does the RLO receive in support of the performance of tasks assigned by the RO?

o How much of their time is devoted to performing records management duties?

Knowledge and Skills

For the RO and RLOs determine the adequacy of professional development, training, and resources they are provided to fulfill their responsibilities.

o Please describe the level of familiarity with 36 CFR and Federal recordkeeping requirements, and knowledge of basic records management terms, definitions, and

concepts, consistent with their duties for the Records Officer, other RM Staff and

RLOs.

o Does the NTSB provide training and other opportunities for professional development to maintain core competencies?

o Does the NTSB provide internal training in RM and NTSB RM policies specifically tailored for RM staff and RLOs? If yes, from whom do they receive

this training and how often? Please provide samples.



Appendix E



Records Management Guidance:

Obtain copies of all NTSB records management directives, orders, bulletins, and similar

authoritative issuances and evaluate their adequacy.

Does NTSB have policies and procedures readily accessible on the intranet? How are updates to policies and procedures disseminated to staff?

Are records management responsibilities for records management staff defined in the guidance?

Does NTSB have a records management orientation for new employees, and are employees informed that they are responsible and accountable for keeping accurate and

complete records of their activities? Are exit briefings conducted for departing

employees and senior officials?

Controls and Oversight:

Does NTSB have written procedures for oversight activities to ensure the proper management of records?

Does NTSB conduct surveys of the operation of the records management program at all organizational levels? Does this include an inventory of business processes and existing

records to identify any unscheduled records?

Creation, Maintenance, Storage, and Disposition:

Does NTSB have written guidance for handling information that is restricted from release under the Privacy Act or for records containing other information exempt from disclosure

under FOIA?

Does NTSB have written guidance for handling classified records and information and for ensuring segregation from unclassified records and information?

Does NTSB have written procedures that address records management controls in alternate work site locations? What records issues have been identified and addressed?

Do NTSB procedures, directives, and other issuances cover the record status of working papers/files and drafts?



Appendix E



Oversight Records:

For what industries or organizations does the agency conduct oversight?

Does the agency receive any records from the organizations over which it has oversight? o If yes, describe the records received, including format and media.

What records series does the agency create and maintain for its oversight function?

Are these records maintained in hard copy or electronic media?

Are any of these records permanent? If yes, are they maintained as hard copy or electronic records?

Are these records maintained separately from other agency records?

How does the agency manage Confidential Business Information (CBI), PII, Classified or sensitive information received from organizations over which it has oversight?

Does the agency manage these records differently from other agency records?

o Audits o Inspections o Guidance and regulations o Performance records o Reports o Contracts

Files Maintenance:

Determine if NTSB is maintaining an accurate, current, and NARA-approved agency records

schedule covering all records in its custody. Does the records schedule cover records in all

media? Are they implementing the schedule?

Determine if records management related guidance provides adequate standards and procedures

for classifying, indexing, filing, and retrieving records. Specifically, is there guidance concerning

the grouping of “like” records (those defined as a series of records in the agency records

schedule), the annual cutoff and retirement (removal from prime office space of records no

longer necessary for daily business) of records, and the identification of records upon retirement

necessary for their future retrieval?



Appendix E



Determine whether this standardized reference guidance has been sufficiently disseminated.

Specifically, are those within the agency who are responsible for identifying, retrieving, and

refiling records aware of this guidance?

Does NTSB guidance specify a well-defined filing structure through specified file labels for records to be used on file folders?

Does NTSB guidance specify well-defined file structures, naming conventions, and taxonomies for electronic records? Does it ensure that these file structures, naming

conventions, and taxonomies are used by staff when establishing and implementing

electronic recordkeeping systems?

Does the NTSB file plan include disposition instructions and citations to records schedules?

Does NTSB have procedures in place to ensure that permanent records are identified and filed separately from temporary records?

Inactive Records Storage:

Is NTSB storing permanent or unscheduled records at commercial or agency storage facilities, and has the agency created documentation sufficient to identify and locate

files?

Is NTSB storing records under the appropriate conditions based on the retention period of the records and in compliance with 36 CFR 1232.12?

Are non-textual records being stored in environmentally appropriate space?

Before transferring records to a records storage facility has the agency created documentation sufficient to identify and locate files?

Records Disposition:

Which records management staff are responsible for the activities related to the disposition of records?

Who approves destructions/removals of records? Are records authorized for disposal only as provided in agency records schedules?



Appendix E



Has NTSB issued a handbook, guidance, or a directive that contains records disposition policies and procedures as well as the NARA-approved records schedules?

Are permanent records transferred to NARA according to the NARA-approved schedules?

Are temporary records destroyed when NARA-approved retention periods expire?

What controls does the NTSB have in place to prevent unauthorized removal or alienation of records?

What controls exist to ensure that records are not destroyed prior to their approved retention period or while they are covered by litigation hold or freeze?

Are unauthorized destruction/dispositions reported to NARA?

Electronic Records Management Requirements (Not Including E-mail):

Obtain copies of any guidance/memoranda formally assigning this responsibility.

Determine if NTSB staff who work regularly with electronic records are familiar with all

electronic records management guidance that has been issued.

Has NTSB assigned responsibility for development and implementation of guidance on the management of all records created, received, maintained, used, or stored on electronic

media?

Has NTSB integrated the management of electronic records with other records and information resources management programs?

Does NTSB ensure that records management functionalities are incorporated into the design, development, and implementation of its electronic information systems?

Does NTSB have procedures in place to ensure that records management requirements, including recordkeeping requirements and disposition, are addressed before approving

new electronic information systems or enhancements to existing systems?

Does the records management staff work with information technology staff and does records management staff participate in the design, development, and implementation of

new electronic information systems?



Appendix E



Determine if NTSB has any procedures in place for ensuring that records management

requirements, including recordkeeping requirements and disposition, are addressed before

approving new electronic information systems or enhancements to existing systems. Obtain

copies.

If the records management official issues written comments concerning new or enhanced

electronic information systems, obtain copies. Determine if such comments are used in

evaluating systems or enhancements.

Migration:

Determine if NTSB has procedures in place for identifying electronic records that have been

created on media that is becoming obsolete.

Does NTSB have migration strategies for electronic records and information and associated metadata?

Shared Drives and Unstructured Data:

Does NTSB have policies and procedures that address records and information stored on shared drives? If yes, do the policies and procedures cover permissions, access controls,

and acceptable formats for long-term records and information?

Does the record management staff work with information technology staff to ensure the integrity of the shared drives?

ERMS/RMA:

Does NTSB or any office/component unit within the agency currently have a fully functioning Electronic Records Management System (ERMS) or a Records Management

Application (RMA) for maintaining and preserving electronic records?

Cloud Computing:

Does NTSB or any office/component unit use cloud computing technologies? If yes, what records management safeguards have been put in place?

Does RM staff maintain any inventory of records that are being stored in the cloud?



Appendix E



Training:

Has NTSB developed and implemented an internal training program for records management staff covering their roles and responsibilities pertaining to records creation,

maintenance, and disposition activities including the application of agency records

management guidance?

APPENDIX F

ACRONYMS AND ABBREVIATIONS

CIO Chief Information Officer

CFR Code of Federal Regulations

DMS Docket Management System

EDMS Electronic Document Management System

ERMS Electronic Records Management System

FOIA Freedom of Information Act

FRC Federal Record Center

IIC Investigator-In-Charge

IT Information Technology

NARA National Archives and Records Administration

NTSB National Transportation Safety Board

OMB Office of Management and Budget

PoCA Plan of Corrective Action

RO Records Officer

RM Records Management

RMSA Records Management Self-Assessment

WNRC Washington National Records Center

NATIONAL ARCHIVES and

RECORDS ADMINISTRATION

records management oversight inspection report …management self-assessment (rmsa).1 past scores on...

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